07028_CLT Tank Truck_Additional Assessment WP_ Approval Letter 20221011

Via Email October 7, 2022

North Carolina Department of Environmental Quality Division of Waste Management – Brownfields Program 1646 Mail Service Center Raleigh, North Carolina 27699-1646

Attn: Ms. Carolyn Minnich Re: Revised Brownfields Assessment Work Plan Charlotte Tank Truck
2200 Border Drive
Charlotte, Mecklenburg County, North Carolina Brownfields Project No. 07028-03-060 H&H Job No. AWT-001
Dear Carolyn:

1.0 Introduction

On behalf of AWTBorder, LLC, Hart & Hickman, P.C. (H&H) has prepared this Work Plan to
conduct Brownfields assessment activities at the Charlotte Tank Truck Brownfields property
(Brownfields Project No. 07028-03-060) located at 2200 Border Drive in Charlotte, Mecklenburg
County, North Carolina (subject Site or Site). The Site consists of one approximately 2.23-acre
parcel (Mecklenburg County Parcel ID 071-051-18) of land that is developed with an
approximately 97,100 square foot (sq ft) industrial building. The Site is located in the Wesley
Heights neighborhood west of Uptown Charlotte. Additionally, the Site is located downgradient
of the Berryhill-Thrift Road and Fleming Laboratories-RFRU Brownfields properties
(Brownfields Project Nos. 21061-17-060 and 16041-12-060, respectively).

Proposed redevelopment plans for the Site include razing the existing Site building and minimal
ground disturbance for the construction of a seven-story multi-family residential structure with
associated amenity spaces and a two-story approximately 65,000 square foot (sq ft) parking garage.
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The ground floor of the proposed structure will predominantly consist of a podium construction
parking garage with a small amenity/common area space located in the eastern portion of the
Brownfields property. The current redevelopment plans have been changed to eliminate the
previously proposed ground-floor residential units. The upper floors (i.e., floors 3-7) of the
proposed building will consist of approximately 205,000 sq ft of residential space. A copy of the
current proposed redevelopment plans is included in Appendix A (though note that the residential
“loft units” shown on these plans will be replaced with non-residential spaces (e.g., amenities). A
Site location map is provided as Figure 1, and the Site and surrounding area are shown in Figure
2.

H&H reviewed available resources to obtain information regarding historical uses of the Site and
identify areas of potential environmental concern for proposed Brownfields assessment activities.
A brief summary of our review is provided in the following section.

2.0 Site Background

From the 1940s until approximately 1970, the Charlotte Tank Corporation manufactured tanks and
assembled tank trucks at the Site. Details associated with former Site operations were not available
for H&H’s review. Additionally, the Site is currently occupied by Atlantic Wood & Timber, LLC,
a multi-family residential framer.

As previously mentioned, the Site is located downgradient of the Berryhill-Thrift Road
Brownfields property (2317 Thrift Road, Brownfields Project No. 21061-17-060) and Fleming
Laboratories-RFRU Brownfields property (2215 Thrift Road, Brownfields Project No. 16041-12-
060). Berryhill-Thrift Road was developed by the late 1940s with a commercial building that was
utilized as the Cities Service Oil Company bulk plant in the 1950s and the American Mineral
Spirits Company in the 1960s. From approximately the mid-1980s until the early to mid-1990s,
Cherokee Oil Company utilized the Berryhill-Thrift Road property as a waste oil processing
facility that accepted waste oil and various hazardous substances. Hazardous material was
reportedly blended with waste oil and stored in roll-off containers, drums, tanker truck trailers,
aboveground storage tanks (ASTs), underground storage tanks (USTs), and aboveground spill
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containment basins. In July 1991, the EPA conducted a criminal investigation associated with
reported improper handling and improper disposal of hazardous materials. Subsequent emergency
removal actions were completed by the U.S. Environmental Protection Agency (EPA) Emergency
Response and Removal Branch (ERRB).

From 2017 through 2018, assessment activities were completed under the purview of the North
Carolina Department of Environmental Quality (DEQ) Brownfields Program and Superfund
Section. These activities are documented in H&H’s Brownfields Assessment Report dated
February 13, 2018, and Remedial Investigation Report (RI Report) dated May 26, 2020. As part
of the assessment activities, groundwater samples were collected from the southern portion of the
Berryhill-Thrift Road Brownfields property (approximately 150 ft north and upgradient of the Site
[TMW-7]), the central portion of the Suburban Propane facility (approximately 180 ft northwest
and upgradient of the Site [TMW-6]), and from a location adjacent and downgradient of the Site
(TMW-9). Laboratory analytical results from these locations indicated chromium (12 micrograms
per liter [µg/L]) and the chlorinated compounds 1,1-dichloroethane (52 µg/L), 1,1-dichloroethene
(21 µg/L), tetrachloroethylene (PCE, 57 µg/L), and trichloroethylene (TCE, 10 µg/L) were
detected above the Title 15A NCAC 2L .0202 Groundwater Standards (2L Standards) in the
groundwater sample TMW-6 collected from the Suburban Propane facility. No other compounds
were detected above the 2L Standards in the three aforementioned groundwater samples.

The Fleming Laboratories-RFRU Brownfields property (2215 Thrift Road) is located to the
northeast and topographically upgradient of the subject Site. Former operations at the facility
included the manufacturing of bulk pharmaceuticals for animals. According to information
provided in the 2018 RI Report, soil impacts were discovered at the facility following a surface
release of arsenic acid from a tanker truck product line in 1984. In addition, soil and groundwater
impacts were discovered following an investigation of aniline, methanol, and xylene underground
storage tanks (USTs) in the early 1990s; and soil impacts were discovered following an
approximate 1,000-gallon release of arsanilic acid from an AST in February 1999. Groundwater
sampling data indicates chlorinated compounds, arsenic, chromium, and nickel were identified in
upgradient and/or downgradient portions of the facility property.

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To address groundwater impacts associated with the upgradient Fleming Laboratories-RFRU
Brownfields Property, the Site was entered into the DEQ Brownfields Program. On April 5, 2007,
a Brownfields agreement (BFA) was executed for the Site between DEQ and W.R. Deal Holdings,
LLC. According to the BFA, chlorinated compounds 1,1-dichloroethane (175 µg/L), 1,1-
dichloroethene (up to 66 µg/L), cis-1,2-dichloroethylene (108 µg/L), and vinyl chloride (up to 231
µg/L), and petroleum compounds benzene (up to 22 µg/L), ethylbenzene (1,400 µg/L), and xylene
(up to 3,900 µg/L) were detected in groundwater in the downgradient portion of the Site. Based
upon H&H’s review of assessment activities completed at the aforementioned Brownfields
properties and environmental investigations conducted for other facilities in the general Site
vicinity, evaluation of polychlorinated biphenyls (PCBs) in Site media does not appear warranted.
As such, this Work Plan proposes the assessment of organic compounds and metals at the Site to
further evaluate groundwater conditions associated with the upgradient Fleming Laboratories-
RFRU and Berryhill-Thrift Road Brownfields properties and the upgradient Suburban Propane
facility.

On October 4, 2022, H&H, the property owner, and the property owner’s environmental counsel
attended a virtual meeting with DEQ Brownfields personnel at the Site to discuss Site history,
areas of potential environmental concern, proposed redevelopment plans, amending the
Brownfields Agreement to authorize high-density residential use, potential data gaps, and the
scope of Brownfields assessment activities needed to address the data gaps. The BFA includes
certain provisions related to the management of Site media (e.g., soil, groundwater, vapor, etc.)
during future redevelopment. In addition, the BFA currently limits land use to commercial
purposes. To address DEQ requests for additional assessment at the Site to support AWTBorder,
LLC’s request to amend the Brownfields Agreement to authorize future high-density residential
land use, H&H proposes to conduct soil, groundwater, and vapor intrusion assessment activities
to further evaluate potential impacts at the Site. Proposed Brownfields assessment activities are
outlined in the following sections.

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3.0 Brownfields Assessment Activities
The proposed Brownfields assessment activities will be performed in general accordance with the
DEQ Inactive Hazardous Sites Branch (IHSB) Guidelines for Assessment and Cleanup
(Guidelines) dated July 2021, the DEQ Division of Waste Management (DWM) Vapor Intrusion
Guidance dated March 2018, Brownfield’s Vapor Intrusion Assessment Work Plan & Report
Checklist (VI Checklist) dated July 2021, and the most recent versions of the U.S. EPA Region IV
Laboratory Services and Applied Science Division (LSASD) Field Branches Quality System and
Technical Procedures guidance.

Prior to conducting field activities, H&H will contact North Carolina 811 One-Call, the public
utility locator service, to mark subsurface utilities at the Site. H&H will also team with a private
utility locator to identify and mark locations of sub-grade utilities at the Site that may not be
marked by the public locator. In addition, H&H will obtain a Subsurface Investigation Permit
from Mecklenburg County.

3.1 Receptor Survey
H&H will perform a Brownfields receptor survey in accordance with DEQ Brownfields Section
guidance. The receptor survey will use the Brownfields Property Receptor Survey Form and will
include information about land use in the Site area including zoning. H&H will also conduct a
field search for water supply wells, basements, utility manways and chases, storm sewers, other
underground utilities, drains, and surface water within a 1,500 ft radius of the Brownfields property
boundaries.

3.2 Soil Assessment Activities

H&H proposes to advance soil borings to evaluate potential impacts from historical operations at
the Site relative to proposed redeveloped plans (i.e., areas of potential soil disturbance [cut]) for
on-Site management and/or off-Site disposal purposes. As previously mentioned, proposed
redevelopment plans for the Site include minimal ground disturbance for the construction of the
multi-family residential and parking structure. As such, the proposed soil borings described below
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will be advanced to depths of up to 5.5 feet below ground surface (ft bgs). The approximate
locations of the proposed soil borings in conjunction with the proposed redevelopment are shown
on Figure 3.

H&H proposes to advance each boring via a decontaminated, stainless steel hand auger and/or
direct-push technology (DPT) drilling rig to depths up to approximately 5.5 ft bgs. Continuous soil
samples will be collected from the borings and logged for lithological description and field
screened for indication of potential impacts by observation for staining, unusual odors, and the
presence of volatile organic vapors using a calibrated photoionization detector (PID). Soil borings
will be advanced at the following locations for laboratory analyses, which are also described in
Table 1:

• SB-1 (co-located with SG-1), SB-5, and SB-6 will be advanced to approximately 5 ft bgs
in the southwestern portion of the Site within the footprint of the proposed parking garage.
If field observations indicate potential impacts based on elevated PID readings, staining,
and/or petroleum/solvent odors, a sample will be collected from a 2-ft interval
representative of the potential impacts. If no evidence of potential impacts is observed,
soils from the borings will be composited in aliquots (two per boring) to comprise
Composite Soil Sample 1. The soil sample will be submitted for laboratory analysis of
semi-VOCs (SVOCs) by EPA Method 8270 and Resource Conservation and Recovery Act
(RCRA) metals plus hexavalent chromium by EPA Methods 6020/7471/7199.

• SB-2 (co-located with SG-2), SB-3 (co-located with SG-3), and SB-9 (co-located with
TMW-3) will be advanced to approximately 5 ft bgs in the east-central portion of the Site
within the footprint of the proposed parking garage. If field observations indicate potential
impacts based on elevated PID readings, staining, and/or petroleum/solvent odors, a sample
will be collected from a 2-ft interval representative of the potential impacts. If no evidence
of potential impacts is observed, soils from the borings will be composited in aliquots (two
per boring) to comprise Composite Soil Sample 2. The soil sample will be submitted for
laboratory analysis of SVOCs by EPA Method 8270 and RCRA metals plus hexavalent
chromium by EPA Methods 6020/7471/7199.
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• SB-4 (co-located with SG-4), SB-7, and SB-8 will be advanced to approximately 5 ft bgs
in the southeastern portion of the Site in the footprint of the proposed amenity/common
area space. If field observations indicate potential impacts based on elevated PID readings,
staining, and/or petroleum/solvent odors, a sample will be collected from a 2-ft interval
representative of the potential impacts. If no evidence of potential impacts is observed,
soils from the borings will be composited in aliquots (two per boring) to comprise
Composite Soil Sample 3. The soil sample will be submitted for laboratory analysis of
SVOCs by EPA Method 8270 and RCRA metals plus hexavalent chromium by EPA
Methods 6020/7471/7199.

In addition to the composite soil samples described above, three representative grab soil
samples will be collected for analysis of volatile organic compounds (VOCs). Based on the
results of field screening, a grab soil sample will be collected from the aliquot exhibiting
the highest likelihood for impact in each composite area. If field screening results do not
identify the obvious presence of impacts in an aliquot soil sample, the grab samples will
be collected from the interval with the highest PID reading. The grab soil samples will be
submitted for laboratory analysis of VOCs by EPA Method 8260.

• SB-10 will be advanced to approximately 5 ft bgs in the existing Site building within the
footprint of the proposed parking garage and a proposed elevator location (adjacent to SSV-
3). If field observations indicate potential impacts based on elevated PID readings,
staining, and/or petroleum/solvent odors, a sample will be collected from a 2-ft interval
representative of the potential impacts. If no evidence of potential impacts is observed, a
sample will be collected from surficial soil (approximately 0-2 ft bgs). The soil samples
will be submitted for laboratory analysis of VOCs by EPA Method 8260, SVOCs by EPA
Method 8270, and RCRA metals plus hexavalent chromium by EPA Methods
6020/7471/7199.

Soil samples will be placed in dedicated laboratory-supplied sample containers, labeled with the
sample identification, date, and requested analysis, and placed in a laboratory-supplied cooler with
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ice. The soil samples will then be submitted to a North Carolina-certified laboratory, Contest
Analytical Laboratory (Contest), under standard chain of custody protocols for analyses as
described above. Information pertaining to Contest’s certifications and accreditations is provided
in Appendix B.

Following sampling activities at each location, including the collection of soil gas and groundwater
samples as discussed in Sections 3.2 and 3.3, the soil borings will be properly abandoned with soil
cuttings and/or bentonite and the surface will be repaired similarly to pre-sampling conditions.
Additionally, the soil sample locations will be recorded using a hand-held GPS unit.
3.3 Groundwater Assessment Activities H&H proposes to subcontract with a North Carolina licensed drilling contractor to advance borings
for the installation of three temporary monitoring wells using a DPT drill rig with auger and/or air
rotary capabilities. The approximate locations of the proposed temporary monitoring wells in
conjunction with the proposed redevelopment plans are shown on Figure 3, and are described
below:

• TMW-1 will be installed along the western Site property boundary downgradient of
Suburban Propane;
• TMW-2 will be installed along the northeastern Site property boundary downgradient of
the Berryhill-Thrift Road Brownfields property;
• TMW-3 will be co-located with soil boring SB-9 and installed within the footprint of the
proposed parking garage and downgradient of the Fleming Laboratories-RFRU
Brownfields property; and
• If present and in acceptable condition, permanent monitoring wells MW-2, MW-2B, and
TW-2 will be developed and sampled.

During drilling, soil samples will be collected and logged for lithologic description and field
screened for the presence of staining and elevated concentrations of volatile organic vapors using
a calibrated PID. The temporary monitoring wells will be constructed of 1-inch diameter PVC
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with 10 or 15 ft of pre-pack well screen (due to sampling for metals) set to bracket the water table
(estimated at between approximately 15 to 25 ft bgs) and 1-inch diameter PVC well casing to the
ground surface. A sand filter pack will extend from below the base to approximately 2 ft above
the top of the pre-packed well screens followed by at least 2 ft of hydrated bentonite. The
temporary monitoring well will be developed by removing a minimum of 3 to 5 well volumes and
observing stable field parameters (i.e., pH ± 0.1 SU and conductivity varies no more than 5%).

After development, groundwater samples will be collected from the temporary monitoring wells,
and existing monitoring wells MW-2, MW-2B, and TW-2 if the wells are located during the field
event. Existing and temporary monitoring wells will be redeveloped at least 24 hours prior to
sampling. The location of monitoring wells MW-2, MW-2B, and TW-2 and the proposed
temporary monitoring wells are depicted in Figure 3.

Prior to purging, depth to groundwater information will be collected for each monitoring well
sampled. A groundwater sample will then be collected utilizing low flow/low stress purging
techniques using a peristaltic pump and disposable polyethylene tubing. The intake point of the
pump tubing will be placed approximately in the mid-portion of the screened interval of the well
and groundwater will be removed at a rate no greater than 200 milliliters per minute. H&H will
utilize a water quality meter to measure pH, temperature, dissolved oxygen, oxidation reduction
potential, turbidity, and specific conductivity at 3 to 5-minute intervals during purging. Purging
will be considered complete when water quality parameters stabilize (i.e., pH ± 0.1 SU,
conductivity varies no more than 5%, and turbidity is less than 10 NTUs).

Once groundwater parameters stabilize, a groundwater sample from each monitoring well will be
collected directly into laboratory supplied sample containers. VOC samples will be collected using
the “soda straw” method to minimize volatile loss through the peristaltic pump head. Specifically,
sample tubing will be removed from the well and used to fill the sample containers by reversing
the flow direction of the peristaltic pump. The sample containers will be labeled with the sample
identification, date, and requested analysis, and then placed in a laboratory supplied cooler and
iced. The groundwater samples will be delivered to Contest under standard chain of custody
protocols for analysis of VOCs by EPA Method 8260, SVOCs by EPA Method 8270, and RCRA
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metals by EPA Methods 6020/7471. Note that groundwater samples will also be analyzed for
aniline by EPA Method 8270 and nickel by EPA Method 6020 based on historical sampling results
performed at the upgradient Fleming Laboratories-RFRU Brownfields property. Table 1
summarizes the proposed groundwater samples rationale and associated analyses. Information
pertaining to Contest’s certifications and accreditations is provided in Appendix B.

Upon completion of groundwater sampling activities, the temporary monitoring well casings will
be surveyed to evaluate the direction of groundwater flow at the Site. The wells will then be
properly abandoned by a licensed well driller and the ground surfaces will be repaired to generally
match pre-drilling conditions. The groundwater sample locations will be recorded in the field
using a hand-held GPS unit.

3.4 Vapor Intrusion Assessment Activities
H&H proposes to conduct sub-slab and exterior soil gas assessment activities to evaluate the
potential for structural vapor intrusion into the future Site structure. The approximate locations of
the proposed sub-slab gas samples and exterior soil gas samples in conjunction with the proposed
redevelopment plan are shown on Figure 3, and are described below:

• Four sub-slab gas samples (SSV-1 through SSV-4) will be collected from the existing Site
building within the footprint of the proposed parking garage and a proposed elevator
location (SSV-3);
• One exterior soil gas sample (SG-1) will be co-located with soil boring SB-1 and installed
within the footprint of the proposed parking garage;
• Two soil exterior gas samples (SG-2 and SG-3) will be co-located with soil borings SB-2
and SB-3, respectively, and installed within the footprint of the proposed parking garage;
and
• One exterior soil gas sample (SG-4) will be co-located with soil boring SB-4 and installed
within the footprint of the proposed amenity/common area space.

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H&H proposes to install each sub-slab gas monitoring point by using a hammer drill and 5/8-inch
diameter decontaminated drill bit to advance the boring through the concrete slab. Slab thicknesses
and sub-slab materials (i.e., soil, gravel, etc.) will be documented at each location. Following
concrete borehole advancement, loose concrete cuttings will be removed from the boring using a
bottlebrush and vacuum with a high-efficiency particulate air (HEPA) filter. A Cox-Colvin Vapor
Pin™ (vapor pin) assembly (brass sampling point and silicone sleeve) will be seated in the
borehole using an installation/extraction tool and hammer. The vapor pin will be connected at the
surface with ¼-inch new and dedicated Teflon® tubing and will be installed as temporary sub-slab
gas points. Sample points will be allowed to equilibrate for at least two hours following
installation.

H&H proposes to install each exterior soil gas point to a depth of approximately 5.5 ft bgs using a
decontaminated stainless steel hand auger. The exterior soil gas points will each be installed with
a 6-inch long 0.010-inch slot stainless steel screen set at the base of the boring connected to the
surface with ¼-inch new and dedicated Teflon® tubing. The annular space will be filled with filter
sand followed by a bentonite seal to prevent short-circuiting of air from the surface. The exterior
soil gas points will be installed as temporary points and will be allowed to equilibrate for a
minimum of 48 hours after installation and prior to sample collection described below.

Prior to vapor sampling activities, a leak check will be conducted by constructing a shroud around
the sample train at each exterior soil gas and sub-slab gas sampling point and flooding the air with
helium gas. Helium concentrations inside the shroud will be measured using a calibrated helium
gas detector and maintained at concentrations of approximately 10% to 20% for the duration of
the leak check. Using a syringe and three-way valve, a minimum of three sample train volumes
(including both the tubing and annulus) will be purged at a maximum flow rate of 200 mL/min,
and a sample will be collected from the sample tubing outside the shroud into a Tedlar bag and
analyzed using the helium gas detector to ensure that helium concentrations are less than 10% of
the helium concentrations measured within the shroud. Note that the helium meter will not be
connected to the sampling train, as it is used independently to measure helium within the shroud
and from a Tedlar bag that is connected to the sampling train.

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Following a successful leak check, the samples will be collected using batch-certified 1-liter or 3-
liter stainless steel Summa® canisters connected to an air-flow regulator calibrated by the
laboratory for collection of a sample at a rate of up to approximately 200 milliliters per minute.
To conduct the sampling, the intake valve on the Summa® canister will be fully opened to begin
collection of the sample and vacuum readings on the Summa® canister will be recorded prior to
and following the sampling period to ensure adequate sample volume was collected. A vacuum
will be maintained within the canisters at the conclusion of the sampling event, and vacuum
measurements which include pre- and post-sampling, and sample collection time durations will be
recorded on the chain-of-custody. Canisters that have lost greater than 10% of their vacuum as
determined by comparing the vacuum recorded by the laboratory prior to shipment and the vacuum
recorded in the field during the leak test procedures will not be used for sampling. In addition, a
minimum of vacuum of five inches of mercury will be maintained on the sample canisters until
the conclusion of the sampling event.

After sample collection, the intake valve will be closed, and the regulator will be disconnected
from the sample canister. The canisters will be placed in laboratory supplied shipping containers,
properly labeled, and shipped under standard chain-of-custody protocols to SGS North America
Inc. – Dayton (SGS) for analysis of VOCs by EPA Method TO-15. Table 1 summarizes the
proposed sub-slab gas and exterior soil gas samples and associated analyses. Information
pertaining to SGS’s certifications and accreditations for TO-15 in New Jersey (North Carolina
does not provide TO-15 certifications) is provided in Appendix B.

Upon completion of sampling activities, exterior soil gas and sub-slab gas point locations will be
recorded in the field using a hand-held GPS unit. The exterior soil gas and sub-slab gas points
will then be properly abandoned and surfaces will be repaired to generally match pre-sampling
conditions.
3.5 Quality Assurance/Quality Control Samples

Non-dedicated equipment and tools will be decontaminated prior to use at each boring or sampling
location or following exposure to soil, soil gas, sub-slab gas, and/or groundwater samples.
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Decontamination of non-dedicated equipment will follow U.S. EPA Region IV guidance
(LSASDPROC-205-R4) and will consist of wiping the equipment clean, a water-rinse of the
equipment, washing the equipment in water and detergent (i.e., Liquinox® or Luminox®), and a
final rinse with water. The process will be repeated for grossly contaminated non-dedicated
equipment.

For quality assurance and quality control purposes (QA/QC), and to evaluate the reproducibility
of the sample results, H&H will collect the following: 1) one duplicate soil sample; 2) one
duplicate groundwater sample; 3) one duplicate exterior soil gas and one duplicate sub-slab gas
sample. The duplicate samples will be submitted for the same laboratory analysis as their
respective parent samples. For the duplicate soil gas/sub-slab gas samples, H&H will utilize a
laboratory-supplied “T-sampler” which allows for the collection of two samples from the same
location simultaneously. Per laboratory standard operating procedures, a vacuum of
approximately five inches of mercury will be maintained within all canisters at the conclusion of
the sampling event. In addition, one laboratory-provided trip blank sample will be included for
every cooler/shipment containing groundwater samples for VOC analysis.

Laboratory QA/QC procedures will be employed to ensure appropriate sample handling and
analysis and to aid in the review and validation of the analytical data. QA/QC procedures will be
conducted in accordance with the method protocols and will include regular equipment
maintenance, equipment calibrations, and adherence to specific sample custody and data
management procedures. Samples will be analyzed in conjunction with appropriate blanks,
laboratory duplicates, continuing calibration standards, surrogate standards, and matrix spiking
standards in accordance with approved methodologies to monitor both instrument and analyst
performance. Laboratory reporting limits for each analyte will be at or below appropriate
screening criteria, where possible. Additionally, H&H will request that the laboratory include
estimated concentrations for compounds that are detected at levels above the laboratory method
detection limit, but below the laboratory reporting limit (i.e., J flags).

The laboratory analytical data report and QA package for each group of samples submitted to and
analyzed by the subcontracted laboratory will be provided in an appendix to the final report.
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Laboratory QA data consistent with Level II documentation will be requested for this project. A
copy of the completed chain-of-custody record and shipping receipt will be appended to the
corresponding laboratory analytical report included with the final report.
3.6 Investigation Derived Waste (IDW)
Investigation derived waste (IDW) generated during the assessment activities will be thin spread
on-Site. However, if significant impacts are suspected (i.e., high PID readings, free-product, etc.),
the soil cuttings and generated groundwater will be containerized in 55-gallon drums and staged
on-Site pending analytical results of composite IDW samples.
3.7 Reporting
Following completion of the assessment activities and receipt of the analytical data, H&H will
document our findings in a Brownfields Assessment Report. The report will include a description
of the sampling activities, pertinent figures (with appropriate graphic scale and north arrow)
depicting sample locations, tabulated sample data (reported to less than the reporting limit and
compared to applicable regulatory screening levels), soil boring logs (including sub-slab gas and
soil gas monitoring points), laboratory analytical data, a discussion of the data in comparison to
applicable regulatory screening levels with notes where the reporting limit exceeds the regulatory
screening level, risk calculations, IDW manifests (if applicable), and conclusions and
recommendations concerning our activities. The report will be sealed by a North Carolina
Professional Engineer (PE) or Licensed Geologist (LG) and the firm PE/LG numbers will be
provided.

Ms. Carolyn Minnich October 7, 2022
Page 15
03049-001/00418211 https://harthick.sharepoint.com/sites/MasterFiles-1/Shared Documents/AAA-Master Projects/AWTBORDER LLC (AWT)/Work Plan/Final to DEQ/Rev Assessment Work Plan_Charlotte Tank Truck (redline 3).DOCX
Please contact me if you have any questions or require additional information.
Sincerely,
Hart & Hickman, PC
#C-1269 Engineering #C-245 Geology
Justin Ballard, PG Project Manager NC Professional Geologist #2257
Project Contact Information
Property Owner Brownfields Project Manager Environmental Consultant
AWTBorder, LLC Kelly Cummings (980) [e-mail]
Ms. Carolyn Minnich (704) [e-mail]
Hart & Hickman, PC Mr. Justin Ballard (919) [e-mail]
Attachments
10/7/22
Table
Table 1Proposed Sampling PlanCharlotte Tank Truck2200 Border DriveCharlotte, North CarolinaH&H Job No. AWT-001SVOCs RCRA Metals Hexavalent ChromiumEPA 8260D EPA TO-15 EPA 8270E EPA 6020/7470/7471 EPA 7199SB-1/SG-1SB-5SB-6SB-2/SG-2SB-3/SG-3SB-9/TMW-3SB-4/SG-4SB-7SB-8SB-10 ~5Within the footprint of the proposed parking garage and a proposed elevator locationX (Grab) X X XField Duplicate TBDXX XTW-1 ~15-25 Downgradient of Suburban Propane X X XTW-2 ~15-25 Downgradient of the Berryhill-Thrift Road Brownfields property X X XTW-3/SB-9 ~15-25XXXMW-2 UnknownXXXMW-2B UnknownXXXTW-2 UnknownXXXField Duplicate TBDXXXTrip Blank N/AXSSV-1 ~0.5XSSV-2 ~0.5XSSV-3 ~0.5Within the footprint of the proposed parking garage and a proposed elevator locationXSSV-4 ~0.5XSG-1/SB-1 ~5.5XSG-2/SB-2 ~5.5XSG-3/SB-3 ~5.5XSG-4/SB-4 ~5.5 Within the footprint of the proposed ground floor residential units XField Duplicate TBD QA/QC 2X13 10 12 12 5Notes:VOCs = volatile organic compounds; SVOCs = semi-volatile organic compounds; RCRA = Resource Conservation and Recovery ActTBD = parent sample to be determined; QA/QC = quality assurance/quality control; ft bgs = feet below ground surface; N/A = not applicableAnalysesSoil SamplesGroundwater SamplesSoil Gas and Sub-Slab Gas SamplesVOCsQA/QCQA/QCSample IDX (Grab)X (Grab)X (Grab)X (Grab)XXXTOTAL SOIL, GROUNDWATER, SOIL GAS, SUB-SLAB GAS, AND QA/QC SAMPLESSample Depth(ft bgs)Sample Objective~5 (Composite Soil Sample 1)~5 (Composite Soil Sample 2)Soil disturbance in future parking garage areaSoil disturbance in future parking garage area~5 (Composite Soil Sample 3) Soil disturbance in future ground floor residential areaWithin the footprint of the proposed parking garageWithin the footprint of the proposed parking garageDowngradient of the Fleming Laboratories-RFRU Brownfields propertyXXXXXXhttps://harthick.sharepoint.com/sites/MasterFiles-1/Shared Documents/AAA-Master Projects/AWTBORDER LLC (AWT)/Work Plan/Tables10/5/2022Table 1 (Page 1 of 1)Hart & Hickman, PC
Figures
USGS The National Map: National Boundaries Dataset, 3DEP ElevationProgram, Geographic Names Information System, National HydrographyDataset, National Land Cover Database, National Structures Dataset, andNational Transportation Dataset; USGS Global Ecosystems; U.S. CensusBureau TIGER/Line data; USFS Road Data; Natural Earth Data; U.S.Department of State Humanitarian Information Unit; and NOAA NationalCenters for Environmental Information, U.S. Coastal Relief Model. Datarefreshed August, 2021.
SITE LOCATION MAP
CHARLOTTE TANK TRUCK2200 BORDER DRIVECHARLOTTE, NORTH CAROLINA
DATE: 9-29-22
JOB NO: AWT-001
REVISION NO: 0
FIGURE NO: 1
2923 South Tryon Street - Suite 100Charlotte, North Carolina 28203704-586-0007 (p) 704-586-0373 (f)License # C-1269 / # C-245 Geology
TITLE
PROJECT
0 2,000 4,000
SCALE IN FEET
SITE
Path: S:\AAA-Master Projects\AWTBORDER LLC (AWT)\Figures\Figure-1.mxdN
U.S.G.S. QUADRANGLE MAP
CHARLOTTE EAST, NORTH CAROLINA 2022CHARLOTTE WEST, NORTH CAROLINA 2022
QUADRANGLE7.5 MINUTE SERIES (TOPOGRAPHIC)
MW-2
MW-2b
TW-2
REVISION NO. 0
JOB NO. AWT-001
DATE: 9-29-22
FIGURE NO. 2
CHARLOTTE TANK TRUCK
2200 BORDER DRIVE
CHARLOTTE, NORTH CAROLINA
SITE MAP
LEGEND
SITE PROPERTY BOUNDARY
PARCEL LINE
POLE-MOUNTED TRANSFORMER
STORM DRAIN
DUMPSTER
HISTORICAL MONITORING WELL
NOTES:
1.AERIAL IMAGERY AND BASE DATA OBTAINED FROM
MECKLENBURG COUNTY GIS, 2022.
2923 South Tryon Street-Suite 100
Charlotte, North Carolina 28203
704-586-0007(p) 704-586-0373(f)
License # C-1269 / #C-245 Geology
B
O
R
D
E
R

D
R
I
V
E THRIFT
ROAD
FR
E
E
D
O
M

D
R
I
V
E
FLEMING LABORATORIES-
RFRU BROWNFIELDS PROPERTY
(2215 THRIFT ROAD)
SUBURBAN PROPANE
(1333 BERRYHILL ROAD)
MULTI-TENANT COMMERCIAL
(2122 FREEDOM DRIVE)
USPS DROP BOX
(2100 FREEDOM DRIVE)
COMMERCIAL BUILDING
(2135 THRIFT ROAD)
RAILWAY EASEMENT
BERRYHILL-THRIFT ROAD
BROWNFIELDS PROPERTY
(2317 THRIFT ROAD)S:\AAA-Master Projects\AWTBORDER LLC (AWT)\Figures\AWT.001_SITE.dwg, FIG 2, 9/29/2022 2:23:00 PM, shaynes
MW-2
MW-2b
TW-2
REVISION NO. 0
JOB NO. AWT-001
DATE: 9-29-22
FIGURE NO. 3
CHARLOTTE TANK TRUCK
2200 BORDER DRIVE
CHARLOTTE, NORTH CAROLINA
PROPOSED SAMPLE LOCATION MAP
LEGEND
SITE PROPERTY BOUNDARY
PARCEL LINE
POLE-MOUNTED TRANSFORMER
STORM DRAIN
DUMPSTER
HISTORICAL MONITORING WELL
PROPOSED AMENITY SPACE/
COMMON AREA
PROPOSED PARKING DECK
PROPOSED ELEVATOR PIT
PROPOSED SUB-SLAB VAPOR SAMPLE
LOCATION
PROPOSED SOIL VAPOR AND COMPOSITE
SOIL SAMPLE ALIQUOT LOCATION
PROPOSED GROUNDWATER SAMPLE
LOCATION
PROPOSED GROUNDWATER AND SOIL
COMPOSITE SAMPLE ALIQUOT LOCATION
PROPOSED COMPOSITE SOIL SAMPLE
ALIQUOT LOCATION
PROPOSED GRAB SOIL SAMPLE
LOCATION
NOTES:
1.AERIAL IMAGERY AND BASE DATA OBTAINED FROM
MECKLENBURG COUNTY GIS, 2022.
2923 South Tryon Street-Suite 100
Charlotte, North Carolina 28203
704-586-0007(p) 704-586-0373(f)
License # C-1269 / #C-245 Geology
B
O
R
D
E
R

D
R
I
V
E THRIFT
ROAD
FR
E
E
D
O
M

D
R
I
V
E
SUBURBAN PROPANE
(1333 BERRYHILL ROAD)
MULTI-TENANT COMMERCIAL
(2122 FREEDOM DRIVE)
USPS DROP BOX
(2100 FREEDOM DRIVE)
COMMERCIAL BUILDING
(2135 THRIFT ROAD)
RAILWAY EASEMENT
FLEMING LABORATORIES-
RFRU BROWNFIELDS PROPERTY
(2215 THRIFT ROAD)
BERRYHILL-THRIFT ROAD
BROWNFIELDS PROPERTY
(2317 THRIFT ROAD)
SSV-3
SSV-1
SSV-2
SSV-4
SG-1/SB-1
SG-2/SB-2
SG-3/SB-3
SG-4/SB-4
SB-5
SB-6
SB-7
SB-8
TMW-3/SB-9
TMW-2
TMW-1
COMPOSITE SOIL
SAMPLE 1
COMPOSITE SOIL
SAMPLE 3
COMPOSITE SOIL
SAMPLE 2
SB-10
S:\AAA-Master Projects\AWTBORDER LLC (AWT)\Figures\AWT.001_SITE.dwg, FIG 3, 10/7/2022 6:22:52 AM, shaynes
Attachment A
Redevelopment Plans
© 2022 Cline Design Associates, PA. Cline Design Associates, PA expressly reserves its common law copyright and other property rights in these plans. These plans are not to be reproduced, changed, or copied in any form or manner whatsoever, nor are they to be assigned to any third party without first obtaining the expressed written permission and consent of Cline Design Associates, PA. This graphic is for illustrative purposes only and is subject to change.
2200 Border Dr.
Charlotte, NC
022*** | Month 00, 2022
A.01
Upper DeckEntry
F i r e A c c e s s
(4) loft units+
Border Dr.
Lower Deck LevelEntry
P a r k i n g : +2 4 9 sp ( 9’ spaces )
128 sp
115 sp
P
P
1
2
6 sp surface
UPPER DECK PLAN (P.2)
670
670
680680
DogPark
0 30 60 120
D A T A :
Appendix B
Laboratory Certifications and Accreditations

 





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Page 18 of 21

October 11, 2022
Sent Via E-mail Justin Ballard, PG Hart & Hickman, PC 2923 S Tryon Street, Suite 100
Charlotte, NC 28203 [e-mail] Subject: Brownfields Additional Assessment Work Plan Approval Charlotte Tank Truck Brownfields Properties Charlotte, Mecklenburg County
Brownfields Project No 07028-03-060
Dear Mr. Ballard: The North Carolina Department of Environmental Quality (DEQ) Brownfields Program received the Revised Brownfields Assessment Work Plan dated October 7, 2022 (Work Plan). DEQ Brownfields
reviewed this document and determined that comments made by DEQ Brownfields to the previous
version of this work plan have been incorporated as requested. Therefore, DEQ Brownfields approves the work plan. Please be advised that this approval from DEQ Brownfields does not waive any applicable requirement
to obtain any necessary permits, licenses or certifications which may be required from other state or local
entities. If you have any questions, please feel free to contact me at 704-661-0330, or via e-mail at [e-mail] Sincerely,

Carolyn Minnich Brownfields Project Manager

cc: BF Property Management Unit Chris Walker [e-mail] Adam Horner [e-mail] Kelly C [e-mail]